Guidelines for Responsible Investing

The American Investment Council membership has adopted a set of comprehensive responsible investment guidelines that they apply prior to investing in companies and during their period of ownership. The guidelines cover environmental, health, safety, labor, governance and social issues.

The guidelines grew out of a dialogue between AIC members and a group of the world’s major institutional investors, which took place under the umbrella of the United Nations-backed Principles for Responsible Investment (PRI).

The guidelines call for AIC member firms to:

1.

Consider environmental, public health, safety, and social issues associated with target companies when evaluating whether to invest in a particular company or entity, as well as during the period of ownership.

2.

Seek to be accessible to, and engage with, relevant stakeholders either directly or through representatives of portfolio companies, as appropriate.

3.

Seek to grow and improve the companies in which they invest for long-term sustainability and to benefit multiple stakeholders, including on environmental, social and governance issues. To that end, American Investment Council members will work through appropriate governance structures (e.g. board of directors) with portfolio companies with respect to environmental, public health, safety, and social issues, with the goal of improving performance and minimizing adverse impacts in these areas.

4.

Seek to use governance structures that provide appropriate levels of oversight in the areas of audit, risk management and potential conflicts of interest and to implement compensation and other policies that align the interests of owners and management.

5.

Remain committed to compliance with applicable national, state, and local labor laws in the countries in which they invest; support the payment of competitive wages and benefits to employees; provide a safe and healthy workplace in conformance with national and local law; and, consistent with applicable law, will respect the rights of employees to decide whether or not to join a union and engage in collective bargaining.

6.

Maintain strict policies that prohibit bribery and other improper payments to public officials consistent with the U.S. Foreign Corrupt Practices Act, similar laws in other countries, and the OECD Anti-Bribery Convention.

7.

Respect the human rights of those affected by their investment activities and seek to confirm that their investments do not flow to companies that utilize child or forced labor or maintain discriminatory policies.

8.

Provide timely information to their limited partners on the matters addressed herein, and work to foster transparency about their activities.

9.

Encourage their portfolio companies to advance these same principles in a way that is consistent with their fiduciary duties.

Guidelines were developed in 2009 under our previous name: Private Equity Growth Capital Council (PEGCC).